Anti-corruption and business ethics

Business ethics are an important part of SSAB’s sustainability and corporate social responsibility work. SSAB conducts its business in some 50 countries around the world.

Global compact and self-assessment

SSAB is a signatory to the UN’s Global Compact and we continually enhance our efforts to protect and respect its 10 principles and promote its spirit within the areas of human rights, labor standards, the environment and anti-corruption.
In line with our sustainability targets, SSAB acts in compliance with our Code of Conduct and behave in accordance with our values. As part of this, SSAB held face-to-face training in anti-corruption and business ethics for the sales organization during the year. Training is based on SSAB’s policies and values, and includes real-life examples and dilemma discussions.

Business ethics

SSAB continues to strive to ensure that the company maintains a global culture of respect, honesty and integrity. By providing a framework for business ethics and compliance, SSAB continues to focus on creating a mature organizational culture that encourages ethical conduct. This framework provides the required support and tools to meet SSAB’s expectation that each and every employee acts with honesty, integrity and responsibility while performing their work.

Global business requires good management of business ethics

Business ethics are an important part of SSAB’s sustainability and corporate social responsibility work. The need for training in business ethics increases as our business becomes more global and complex, and as tougher legislation has been enacted in several countries in recent years.

Ethics and compliance function

A new Ethics and Compliance function was set up during the year in order to further increase our focus on business ethics. The role includes strategic responsibility for work with business ethics, anti-corruption and human rights, and for implementing new legislation and international guidelines in this area. The function is organized as part of the Legal function.

Anti-corruption policy

SSAB’s Anti-Corruption Policy defines SSAB’s zero tolerance approach to bribery and corruption and sets out guidance for our daily operations. The policy provides employees with information on how SSAB defines bribery and improper benefits, and how employees are expected to act in relation to our suppliers, customers and other business partners.

Ethics Line

Everyone working at SSAB must feel a sense of responsibility to react when improprieties are suspected or uncovered. In 2016, SSAB updated its reporting system through which employees can raise concerns and implemented an improved reporting tool known as the Ethics Line. The Ethics Line allows employees to report anonymously serious issues and violations of SSAB’s various policies and local laws. Employees can file a report online or via phone by calling a call center. The Ethics Line will be available in 15 countries. Awareness of the Ethics Line program has been promoted through employee communications.

E-learning in business ethics

All employees are expected to comply with SSAB´s Code of Conduct, Anti-Corruption Policy and to have knowledge of how to report non-compliance in accordance with the Ethics Line. Shared ethical guidelines are fundamental in a global company such as SSAB. Training is organized through a global e-learning module to reach out to all employees in order to provide basic training in business ethics and implement anti-corruption efforts.

Face-to-face training in business ethics

Internal training in business ethics takes place on a regular basis. The training is mainly provided to employees in management, sales and procurement, and is based on SSAB’s values, policies and guidelines. During the course of the training, participants are taught what is meant by corruption and bribery, and how SSAB’s anti-corruption program is structured. This is followed by a discussion focused on practical, real-life examples and dilemma discussions. Experience has shown that business ethics training builds trust and provides for more personal discussions with employees. In 2016, training was mainly provided to employees in the sales organization.

Training in SSAB Americas

As a supplement to the company’s global compliance training, within SSAB Americas, employees receive compliance training in the form of webinars, in-person seminars, lunch events, toolbox talks, intranet publications, email advisories and desktop manuals on a variety of topics including business ethics, the US Foreign Corrupt Practices Act and related anti-corruption laws, anti-trust rules, conflict minerals and harassment prevention training.

Review of business partners

IIn some situations, SSAB reviews the integrity of our business partners more closely. SSAB has an instruction for business ethics reviews that mainly covers agents, certain distributors and consultants who represent SSAB in dealings with any third party. In most cases, there is no need to review the integrity of a business partner more closely, but the instruction means that SSAB may not enter into or renew agreements with business partners that are within the typical risk areas for corruption, before an initial assessment showing that such partners respect our fundamental rules of business ethics. There should be a written agreement between SSAB and the business partner specifying the duties to be performed, adequate and reasonable compensation and the business partner must be competent and qualified to perform the work for which they are being hired. An anti-corruption clause is also implemented in these agreements.

Anti-corruption manual

SSAB has an anti-corruption manual to audit fraud and corruption risks and carried out four audits in subsidiaries during 2016 based on this manual. These audits have not revealed any specific irregularities, but have identified potential to further reduce risks from this perspective. Defined risk mitigation measures are implemented according to agreed action plans.